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Sustainability / ESG

Sustainability Report

A sustainability report is the structured disclosure of a company's environmental, social and governance impacts, risks and opportunities, which under the CSRD must be prepared in accordance with the ESRS and integrated into the management report.

A sustainability report is a company's formalised reporting on its material sustainability impacts, risks and opportunities across the environmental, social and governance (ESG) topic areas. Under the Corporate Sustainability Reporting Directive (CSRD) it becomes part of the management report for in-scope companies and must be prepared in accordance with the European Sustainability Reporting Standards (ESRS). It replaces the voluntary or NFRD-based non-financial statement with a uniform, audit-mandated and machine-readable format.

Structure and mandatory components follow the architecture of the ESRS. The starting point is the double materiality assessment (impact and financial materiality), which determines which topics are reported at all. The cross-cutting standards ESRS 1 (general requirements) and ESRS 2 (general disclosures on governance, strategy, management of impacts, risks and opportunities as well as metrics and targets) are always mandatory. These are supplemented by the topical standards identified as material across the environmental (E1–E5), social (S1–S4) and governance (G1) areas with their respective data points. Throughout, the report is organised along the four reporting pillars: governance, strategy, management of impacts/risks/opportunities, and metrics and targets.

In terms of content, a CSRD-compliant sustainability report requires, among other things, a description of the business model and value chain, EU Taxonomy disclosures, a greenhouse gas inventory covering Scope 1, 2 and 3, transition plans, and social and governance-related metrics. The report must be prepared in the European Single Electronic Format (ESEF) with ESRS taxonomy tagging and is subject to external assurance, initially with limited assurance and, in the future, with reasonable assurance. Through the ongoing Omnibus Regulation, the scope and level of detail of these obligations are currently being revised.

Legal Basis

CSRD (Directive (EU) 2022/2464); ESRS (Delegated Regulation (EU) 2023/2772); Sections 289b et seq., 315b et seq. HGB; ESRS 1 and ESRS 2

Practical Example

A sustainability manager at a mid-sized machinery company prepares the first CSRD report. She first carries out the double materiality assessment and identifies climate change (ESRS E1), own workforce (ESRS S1) and business conduct (ESRS G1) as material. On this basis she collects the required data points, prepares a Scope 1-2-3 greenhouse gas inventory, documents governance structures and targets, and integrates the disclosures in line with ESRS 2 into the management report. Finally, she has the report tagged in ESEF format and reviewed by the auditor with limited assurance.

FAQ

The cross-cutting standards ESRS 1 and ESRS 2 are always mandatory, together with the topical standards determined to be material in the double materiality assessment from environment (E1–E5), social (S1–S4) and governance (G1). Each material standard is reported along the pillars of governance, strategy, management of impacts/risks/opportunities, and metrics and targets.
Under the CSRD the sustainability report is a dedicated section of the management report and thus part of official corporate reporting. It must be tagged in a machine-readable way using the ESRS taxonomy in the European Single Electronic Format (ESEF).
Yes, the CSRD introduces mandatory external assurance. This is initially performed with limited assurance and is intended to be expanded to reasonable assurance in the future.

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